ML20151N730
| ML20151N730 | |
| Person / Time | |
|---|---|
| Issue date: | 12/27/1985 |
| From: | Conway J, Merschoff E NRC, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20151N703 | List: |
| References | |
| REF-QA-99901019 99901019-85-01, 99901019-85-1, NUDOCS 8601030103 | |
| Download: ML20151N730 (8) | |
Text
ORGANIZATION: VALLEY STEEL PRODUCTS COMPANY ST. LOUIS, MISSOURI
(
REPORT INSPECTION INSPECTION NO.-
99901019/85-01 DATE(S):
11/20/85 ON-SITE HOURS:
16 CORRESPONDENCE ADDRESS: Valley Steel Products Company ATTN: Mr. R. Guthrie Vice Pre,ident - Operations Post Office Box 503 St. Louis, Missouri 63166 ORGANIZATIONAL CONTACT: Mr. G. R. Mergel, QA Manager Tri rounNF N!!MRFR-(114) 711 71(iG PRINCIPAL PRODUCT: Ferrous Seamless Pipe and Tubing NUCLEAR INDUSTRY ACTIVITY: None since November 1982.
- 2~- E ASSIGNED INSPECTOR:
M%
. T.' Conway, Rea tive Inspection Section (RIS)
Date OTHER INSPECTOR (S):
J. C. Harper (RIS)
- 2 -2 7W APPROVED BY:
E. W. Merschoff//hief, RIS, Vendor Program Branch Date INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 50, Appendix B and 10 CFR Part 21 B.
SCOPE: This inspection was made as part of an NRC initiated review of compliance by material manufacturers and suppliers with Section III, Subsection NCA-3800 requirements of the ASME Code.
PLANT SITE APPLICABILITY:
Not identified during the inspection.
8601030103 851231 PDR GA999 EMWI
- 99901019 PDR
e ORGANIZATION:
VALLEY STEEL PRODUCTS COMPANY ST. LOUIS, MISSOURI REPORT INSPECTION NO.-
99901019/85-01 RESULTS:
PAGE 2 of 5 A.
Violation Contrary to Section 21.21 of 10 CFR Part 21, appropriate procedures to evaluate deviations or inform the licensee or purchaser of the deviation did not exist (85-01-01).
B.
Nonconformance Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Sections 11.2 and 11.3 of the Quality Assurance Identification and Verification Program, a review of calibration records and vendor audits from 1978 through 1983 indicated that Weber Gage, Radiatronics, and Ehrhardt Tool and "achine Company (ETMC), had performed calibration services for Valley Steel, but Weber Gage and Radiatronics were not on the Qualified Vendor List (QVL). Although ETMC appeared on the QVL, there was no documented evidence that Valley Steel performed surveys or audits of any of the three vendors (85-01-02).
C.
Unresolved Items None.
D.
Other Findings or Comments 1.
Personnel Contacted
- G. Ray Guthrie, Vice President Operations
- G. R. Mergel, QA Manager
- Denotes those attending the exit meeting.
2.
10 CFR Part 21 A review was conducted to verify that Valley Steel Products (VSP) had complied with the posting and procedural requirements of 10 CFR Part 21.
The NRC inspector reviewed a " Notice" which the QA Manager said was posted at VSP's warehouse in Sparta, Illinois.
The Notice, which was attached to Section 206 and 10 CFR Part 21, indicated that suspected noncompliances were tn be reported directly to the QA Manager, VSP or the Vice President-Engineering, Valley Industries. There was no documented evidence that VSP had written a procedure relating to the reporting of defects (See violation 85-01-01).
ORGANIZATION: VALLEY STEEL PRODUCTS COMPANY ST. LOUIS, MISSOURI REPORT INSPECTION NO_-
99901019/85-01 RESULTS:
PAGE 3 of 5 3.
Control of Purchased Material The NRC inspector reviewed all nuclear orders (five) placed with VSP.
The five orders were placed from August 1979 thru November 1982 and included the following:
a)
Western Piping & Engineering - San Francisco, California P0 No. 100086 dated August 15, 1979 was for 400 ft. of 10" carbon steel pipe ordered to Section III, Class 3 of the ASME
- Code, b)
Tube Turns Division - Louisville, Kentucky P0 No. 38778 dated October 20, 1980 was for 12 items of 6" x 161 ft. long carbon steel pipe ordered to Section III, Class 2 of the ASME Code, c)
A. B. Murray - McKeesport, Pennsylvania P0 No. P79249-K1 dated September 11, 1981, was for four items of 18" x 6 ft. long carbon steel pipe ordered to Section III, Class 3 of the ASME Code.
d) dapitolPipe& Steel (CPS)-BalaCynwyd, Pennsylvania P0 No. D-24347-00N dated January 27, 1982 was for 2 ft. of 20" carbon steel pipe ordered to Section III, Class 2 of the ASME Code. The requirements of 10 CFR Part 21 were imposed, and the pipe was.to be shipped to Associated Piping & Engineering in Compton, California, e)
CPS - Bala Cynwyd, Pennsylvania P0 No. D-29878-00N dated November 8, 1982 was for 230 ft.
of 12" carbon steel pipe ordered to Section III, Class 2 of the ASME Code. The requirements of 10 CFR Part 21 were imposed, and the pipe was to be shipped to CP&S in Periand, Texas.
All of the seamless pipe in the above orders was ordered to Grade B of specification SA 106.
The VSP work orders for the five nuclear orders were stamped "ASME III-Nuclear."
ORGANIZATION:
VALLEY STEEL PRODUCTS COMPANY ST. LOUIS, MISSOURI REPORT INSPECTION nn. 44o01019/85-01 RESULTS:
PAGE 4 of 5 The work orders identified processing / coating instructions (e.g., blast /
clean per VSP-CL-500 and final inspection per VSP-INSP-101) and were initialed and dated by QA for heat treat number verification both prior to pulling stock and after processing.
The material for the five orders was purchased from United States Steel (USS) in Lorain, Ohio on VSP P0 No. A8318-RH dated August 31, 1978. Ten specific items to ASTM /ASME SA106-B were identified on the P0 which was stamped "ASME III-Nuclear" and initialed and dated by the QA Manager.
The P0 also contained a statement that:
(a) the material was to be manufactured in accordance with a quality program audited and approved by VSP on May 9,1978 as conforming to NCA-3800 of ASME Section III, (b) 10 CFR Part 21 applied, and (c) no weld repair was allowed.
VSP inspection reports for the five orders were reviewed.
Both in-process (before cutting) and final (after cutting) inspections were performed by a QC inspector per Procedure No. VSP-INSP-101.
The Certified Material Test Reports (CMTR) for the five items from USS referenced the VSP P0,10 CFR Part 21, and Section III certification.
VSP CMTRs referenced the same heat numbers and mechanical and chemical properties as the applicable USS CMTR.
Copies of both the VSP and USS CMTR were sent to the customer when the items were shipped.
It was noted that VSP received a QSC (Materials) in May 26, 1978 as a
" Material Supplier of Carbon & Low Alloy Seamless Pipe & Tubing" at their Sparta, Illinois warehouse. The certificate was renewed (No. 335) in May 1981, and was allowed to expire in May 1984.
4.
Indoctrination & Training The VSP training log was reviewed by the NRC Inspector.
The log described the training session date, class duration, instructor, attendees, and subject matter.
Three QC inspectors were trained in ASME Section III requirements, upgraded QA program, inspection techniques, calibration control system and implementation of the QA manual.
5.
Calibration of Measuring and Test Equipment (M&TE)
The NRC inspector reviewed records for M&TE and certifications for reference standards calibrated by outside vendors. Wall micrometers (S/Ns 5001, 5002, and 5004), a D-meter (S/N 610095),and end measuring rods were properly calibrated in accordance with VSP procedures.
It was noted that VSP received calibrution
ORGANIZATION:
VALLEY STEEL PRODUCTS COMPANY ST. LOUIS, MISSOURI REPORT INSPECTION Hn - 99901019/85-01 RESULTS:
IPAGE 5 of 5 services from Weber Gage, Radiatronics and ETMC from 1978 through 1983, but there was no documented evidence that VSP required these companies to have a QA program, or that a pre-award evaluation and post-award audits were conducted on each. vendor by VSP (See Nonconformance 85-01-02).
Radiatronics calibrated the D-meter in 198? and 1983, ETMC calibrated gage block set No. 77112 in 1978, and Weber Gage calibrated gage block set No. 0800 in 1978.
6.
External Audits The NRC inspector reviewed applicable sections of the QA manual and vendor qualification audit reports.
VSP audited USS in Lorain, Ohio on May 9, 1978, and USS was added to the QVL for nuclear material. The audit of USS was very comprehensive.
The composition of the audit included a checklist as well as a detailed narrative on process control, documentation on plant observations, and traceability of the product through the mill.
There were no records of Vendor Qualification Audits performed on the vendors who supplied VSP with calibration services (See Nonconformance 85-01-02).
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